SEC Comment Letter 0000000000-23-003429 to PROCORE TECHNOLOGIES, INC. (PCOR) (CIK 0001611052) (PCOR)
PROCORE TECHNOLOGIES, INC. (PCOR) (CIK 0001611052)
Date: April 5, 2023 · CIK: 0001611052 · Accession: 0000000000-23-003429
AI Filing Summary & Sentiment
File numbers found in text: 001-40396
Letter
United States securities and exchange commission logo April 5, 2023 Craig F. Courtemanche, Jr. President and CEO Procore Technologies, Inc. 6309 Carpinteria Avenue Carpinteria, CA 93013 Re:Procore Technologies, Inc. Form 10-K for the Year Ended December 31, 2022 Filed March 1, 2023 File No. 001-40396 Dear Craig F. Courtemanche, Jr.: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Year Ended December 31, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations Certain Factors Affecting Our Performance, page 42 1.You state that acquiring new customers and retaining and expanding existing customers' use of your platform is a factor affecting your performance. We note you have provided measures to support new customers (i.e., customer account) and customer retention (i.e., gross retention rate). Please tell us what measure you use to monitor expansion of existing customers and specifically address your consideration to include a quantified discussion of retention rate. In this regard, we note you provided such measure in your recent initial public offering as well as in your 2022 Investor Day presentation.
FirstName LastNameCraig F. Courtemanche, Jr. Comapany NameProcore Technologies, Inc. April 5, 2023 Page 2 FirstName LastName Craig F. Courtemanche, Jr. Procore Technologies, Inc. April 5, 2023 Page 2 Results of Operations Comparison of the Years Ended December 31, 2022 and 2021, page 48 2.You state that the increase in revenue during fiscal 2022 was primarily due to expansion within your existing customers and revenue from new customers added during the year. Please revise to provide the percentage of dollar amount of the revenue increase attributable to each of new and existing customers. Also, refrain from using terms such as "primarily" in lieu of providing a more specific quantitative disclosure. Refer to Item 303(b) of Regulation S-K. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Chen Chen, Staff Accountant, at 202-551-7351 or Kathleen Collins, Accounting Branch Chief, at 202-551-3499 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Benjamin Singer
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United States securities and exchange commission logo
April 5, 2023
Craig F. Courtemanche, Jr.
President and CEO
Procore Technologies, Inc.
6309 Carpinteria Avenue
Carpinteria, CA 93013
Re:Procore Technologies, Inc.
Form 10-K for the Year Ended December 31, 2022
Filed March 1, 2023
File No. 001-40396
Dear Craig F. Courtemanche, Jr.:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Year Ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Certain Factors Affecting Our Performance, page 42
1.You state that acquiring new customers and retaining and expanding existing customers'
use of your platform is a factor affecting your performance. We note you have provided
measures to support new customers (i.e., customer account) and customer retention (i.e.,
gross retention rate). Please tell us what measure you use to monitor expansion of
existing customers and specifically address your consideration to include a quantified
discussion of retention rate. In this regard, we note you provided such measure in your
recent initial public offering as well as in your 2022 Investor Day presentation.
FirstName LastNameCraig F. Courtemanche, Jr.
Comapany NameProcore Technologies, Inc.
April 5, 2023 Page 2
FirstName LastName
Craig F. Courtemanche, Jr.
Procore Technologies, Inc.
April 5, 2023
Page 2
Results of Operations
Comparison of the Years Ended December 31, 2022 and 2021, page 48
2.You state that the increase in revenue during fiscal 2022 was primarily due to expansion
within your existing customers and revenue from new customers added during the year.
Please revise to provide the percentage of dollar amount of the revenue increase
attributable to each of new and existing customers. Also, refrain from using terms such as
"primarily" in lieu of providing a more specific quantitative disclosure. Refer to Item
303(b) of Regulation S-K.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
You may contact Chen Chen, Staff Accountant, at 202-551-7351 or Kathleen Collins,
Accounting Branch Chief, at 202-551-3499 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Benjamin Singer